The case involved an African American couple denied lodging at a Maryland motel in 1988 on the stated ground that it did not rent to local residents; after testers confirmed differential treatment by race, the plaintiffs sued the operators under 42 U.S.C. §§ 1981 and 2000a seeking declaratory relief, an injunction, and compensatory and punitive damages. A jury found that the motel had violated § 1981 and awarded the plaintiffs one dollar in compensatory damages; the district court entered judgment for defendants on the § 2000a claim and denied injunctive relief. On remand from the Fourth Circuit for reconsideration of the plaintiffs’ motion for attorney’s fees under 42 U.S.C. § 1988 in light of Farrar v. Hobby, the court held that the plaintiffs were prevailing parties and awarded them $24,511.09 in fees and expenses, applying the catalyst theory and limiting recovery to hours reasonably expended before an informal settlement offer became known.
In Jackson v. Roseman, the plaintiff filed a state medical malpractice claim against two doctors and an HMO in Maryland's Health Claims Arbitration Office, alleging negligence in the treatment of his cancer and seeking to hold the HMO vicariously liable. The HMO petitioned for removal to federal court, arguing that the claims were preempted by ERISA because they related to an employee welfare benefit plan. The court dismissed the removal petition and granted the motions to remand, holding that the well-pleaded complaint asserted only state common-law negligence claims that did not fall within ERISA's complete preemption provision for civil enforcement actions. The reasoning centered on the conclusion that vicarious liability for medical negligence does not sufficiently relate to the administration of the ERISA plan to trigger federal question jurisdiction or preemption under 29 U.S.C. § 1144(a).
The case involved James Yates, a Black man, suing the Hagerstown Lodge No. 212, Moose International, and a lodge official under 42 U.S.C. §§ 1981, 1982, and 1985(3) after he was allegedly denied guest access to the lodge facilities and membership due to race, despite meeting the stated criteria and being accompanied by a long-time member. The defendants moved to dismiss the six-count complaint. The court granted the motions in part and denied them in part, finding that some allegations adequately stated claims involving property interests under § 1982 and conspiracy under § 1985(3) while others failed to meet pleading requirements or were barred by doctrines such as intracorporate conspiracy.
The case involved plaintiff Richard Blackwell, who had contracted with the Town of Delmar to serve as a Specification Writer/Cost Estimator and whose contract was terminated shortly after he ended a consensual sexual relationship with his supervisor, defendant Linda Fairbank. Blackwell sued the town and two officials under 42 U.S.C. § 1983 for alleged deprivations of property and liberty interests without due process, along with claims for abusive discharge, breach of contract, and civil conspiracy. The court granted the defendants' motion to dismiss in part and denied it in part, dismissing the abusive discharge and breach of contract claims with prejudice while allowing the § 1983 and conspiracy claims to proceed. It reasoned that the contract could create a protected property interest supporting the due process claim, that the breach of contract action was time-barred under Maryland law, and that the abusive discharge claim failed to identify a clear public policy violation, while the conspiracy claim survived because the § 1983 claim was not dismissed.
In Chavis v. Smith, petitioner William Daniel Chavis filed a habeas corpus petition under 28 U.S.C. § 2254 claiming that Maryland unconstitutionally failed to credit time he served in a Georgia prison towards his Maryland sentence, specifically fourteen months of "dead time" after a Georgia conviction was vacated. The district court adopted the magistrate judge's report and recommendation, granting the petition in part by ordering credit for that period of time served. The court reasoned that the claim directly affected the duration of the petitioner's imprisonment so it was not procedurally defaulted, and that Maryland statutes and regulations supported crediting the time under the facts presented rather than an interpretation that would render the law meaningless.
The case involved a lawsuit by Carol Pinder, individually and as representative of her deceased children's estates, against a police officer and the City of Cambridge after her ex-boyfriend was arrested for breaking into her home and threatening her but was released on his own recognizance without notice to her, then set the house on fire killing the three children. The complaint alleged violations of equal protection and substantive due process under the Fourteenth Amendment via 42 U.S.C. §§ 1983 and 1985, plus Maryland state claims for wrongful death and survival actions. The court denied the motion to dismiss the constitutional claims against both defendants and the state claims against the officer, but granted dismissal of the state claims against the city, reasoning that the allegations could support a special relationship or state-created danger theory creating a duty to protect and that qualified immunity and municipal liability issues did not warrant dismissal at this stage.
